Bryan Krough v. Southwest Credit Systems, L.P.

Filing 20

PROTECTIVE ORDER by Magistrate Judge Charles F. Eick re Stipulation for Protective Order. 19 (See document for details) (vmun)

1

GOODMAN LAW FIRM, APC

2

Brett B. Goodman (SBN 260899)
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127
858.757.7262 Direct
858.757.7270 Facsimile
[e-mail]

3
4
5
6

Attorneys for Defendant
Southwest Credit Systems, L.P.

7
8
UNITED STATES DISTRICT COURT

10
GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

9

CENTRAL DISTRICT OF CALIFORNIA

11
12

BRYAN KROUGH,
Plaintiff,

13
14
15
16
17

Case No.: 2:20-cv-08535-JAK-E

v.

STIPULATED PROTECTIVE
ORDER

SOUTHWEST CREDIT SYSTEMS,
L.P.,
Defendants.

18
19
20
21
22
23
24
25
26
27
28
–1–
STIPULATED PROTECTIVE ORDER

1

I.

PURPOSES AND LIMITATIONS
A.

3

confidential, proprietary, or private information for which special

4

protection from public disclosure and from use for any purpose other

5

than prosecuting this litigation may be warranted. Accordingly, the

6

parties hereby stipulate to and petition the Court to enter the following

7

Stipulated Protective Order. The parties acknowledge that this Order

8

does not confer blanket protections on all disclosures or responses to

9

discovery and that the protection it affords from public disclosure and

10
GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

2

use extends only to the limited information or items that are entitled to

11

confidential treatment under the applicable legal principles. The parties

12

further acknowledge, as set forth in Section XIII(C), below, that this

13

Stipulated Protective Order does not entitle them to file confidential

14

information under seal; Civil Local Rule 79-5 sets forth the procedures

15

that must be followed and the standards that will be applied when a

16

party seeks permission from the Court to file material under seal.

17

II.

Discovery in this action is likely to involve production of

GOOD CAUSE STATEMENT

18

A.

19

financial information, including personal financial information regarding an

20

individual’s financial transactions or financial accounts, and other information

21

which is otherwise not available to the public, for which special protection from

22

public disclosure and from use for any purpose other than prosecution of this

23

action is warranted. Such confidential and proprietary materials and information

24

consist of, among other things, confidential business or financial information,

25

information regarding confidential business practices, including information

26

implicating the privacy rights of an individual, information otherwise generally

27

unavailable to the public, or which may be privileged or otherwise protected

28

from disclosure under state or federal statutes, court rules, case decisions, or

This action is likely to involve the production of confidential business or

–2–
STIPULATED PROTECTIVE ORDER

1

common law. Accordingly, to expedite the flow of information, to

2

facilitate the prompt resolution of disputes over confidentiality of

3

discovery materials, to adequately protect information the parties are

4

entitled to keep confidential, to ensure that the parties are permitted

5

reasonable necessary uses of such material in preparation for and in the

6

conduct of trial, to address their handling at the end of the litigation, and

7

serve the ends of justice, a protective order for such information is

8

justified in this matter. It is the intent of the parties that information

9

will not be designated as confidential for tactical reasons and that

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

nothing be so designated without a good faith belief that it has been

11

maintained in a confidential, non-public manner, and there is good

12

cause why it should not be part of the public record of this case.

13

III. DEFINITIONS

14

A.

Action: The above-captioned lawsuit entitled Bryan Krough v.

15

Southwest Credit Systems, L.P., Case No. 2:20-cv-08535-JAK-E.

16

B.

17

designation of information or items under this Order.

18

C.

19

of how it is generated, stored or maintained) or tangible things that

20

qualify for protection under Federal Rule of Civil Procedure 26(c), and

21

as specified above in the Good Cause Statement.

22

D.

23

as their support staff).

24

E.

25

information or items that it produces in disclosures or in responses to

26

discovery as “CONFIDENTIAL.”

27

F.

28

regardless of the medium or manner in which it is generated, stored, or

Challenging Party: A Party or Non-Party that challenges the
“CONFIDENTIAL” Information or Items: Information (regardless

Counsel: Outside Counsel of Record and House Counsel (as well
Designating Party: A Party or Non-Party that designates

Disclosure or Discovery Material: All items or information,

–3–
STIPULATED PROTECTIVE ORDER

1

maintained (including, among other things, testimony, transcripts, and

2

tangible things), that are produced or generated in disclosures or

3

responses to discovery in this matter.

4

G.

5

matter pertinent to the litigation who has been retained by a Party or its

6

counsel to serve as an expert witness or as a consultant in this Action.

7

H.

8

Action. House Counsel does not include Outside Counsel of Record or

9

any other outside counsel.

Expert: A person with specialized knowledge or experience in a

House Counsel: Attorneys who are employees of a party to this

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

I.

Non-Party: Any natural person, partnership, corporation,

11

association, or other legal entity not named as a Party to this action.

12

J.

13

party to this Action but are retained to represent or advise a party to this

14

Action and have appeared in this Action on behalf of that party or are

15

affiliated with a law firm which has appeared on behalf of that party, and

16

includes support staff.

17

K.

18

directors, employees, consultants, retained experts, and Outside Counsel

19

of Record (and their support staffs).

20

L.

21

or Discovery Material in this Action.

22

M.

23

support services (e.g., photocopying, videotaping, translating, preparing

24

exhibits or demonstrations, and organizing, storing, or retrieving data in

25

any form or medium) and their employees and subcontractors.

26

N.

27

designated as “CONFIDENTIAL.”

28

O.

Outside Counsel of Record: Attorneys who are not employees of a

Party: Any party to this Action, including all of its officers,

Producing Party: A Party or Non-Party that produces Disclosure
Professional Vendors: Persons or entities that provide litigation

Protected Material: Any Disclosure or Discovery Material that is
Receiving Party: A Party that receives Disclosure or Discovery
–4–
STIPULATED PROTECTIVE ORDER

Material from a Producing Party.

1
2

IV.

SCOPE

3

A.

The protections conferred by this Stipulation and Order cover not

4

only Protected Material (as defined above), but also (1) any information

5

copied or extracted from Protected Material; (2) all copies, excerpts,

6

summaries, or compilations of Protected Material; and (3) any

7

testimony, conversations, or presentations by Parties or their Counsel

8

that might reveal Protected Material.

9

B.

Any use of Protected Material at trial shall be governed by the

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

orders of the trial judge. This Order does not govern the use of Protected

11

Material at trial.

12

V.

DURATION

13

Even after final disposition of this litigation, the confidentiality

14

obligations imposed by this Order shall remain in effect until a

15

Designating Party agrees otherwise in writing or a court order otherwise

16

directs. Final disposition shall be deemed to be the later of (1) dismissal

17

of all claims and defenses in this Action, with or without prejudice; and

18

(2) final judgment herein after the completion and exhaustion of all

19

appeals, rehearings, remands, trials, or reviews of this Action, including

20

the time limits for filing any motions or applications for extension of

21

time pursuant to applicable law.

22
23
24

VI.

DESIGNATING PROTECTED MATERIAL
A.

Exercise of Restraint and Care in Designating Material for

Protection

25

1.

Each Party or Non-Party that designates information or

26

items for protection under this Order must take care to limit any

27

such designation to specific material that qualifies under the

28

appropriate standards. The Designating Party must designate for
–5–
STIPULATED PROTECTIVE ORDER

1

protection only those parts of material, documents, items, or oral

2

or written communications that qualify so that other portions of

3

the material, documents, items, or communications for which

4

protection is not warranted are not swept unjustifiably within the

5

ambit of this Order.

6

2.

7

prohibited. Designations that are shown to be clearly unjustified or

8

that have been made for an improper purpose (e.g., to

9

unnecessarily encumber the case development process or to

Mass, indiscriminate, or routinized designations are

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

impose unnecessary expenses and burdens on other parties) may

11

expose the Designating Party to sanctions.

12

3.

13

information or items that it designated for protection do not

14

qualify for protection, that Designating Party must promptly notify

15

all other Parties that it is withdrawing the inapplicable

16

designation.

17

B.

If it comes to a Designating Party’s attention that

Manner and Timing of Designations

18

1.

Except as otherwise provided in this Order (see, e.g., Section

19

B(2)(b) below), or as otherwise stipulated or ordered, Disclosure

20

or Discovery Material that qualifies for protection under this Order

21

must be clearly so designated before the material is disclosed or

22

produced.

23

2.

24

following:

Designation in conformity with this Order requires the

25

a.

For information in documentary form (e.g., paper or

26

electronic documents, but excluding transcripts of

27

depositions or other pretrial or trial proceedings), that the

28

Producing Party affix at a minimum, the legend
–6–
STIPULATED PROTECTIVE ORDER

1

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”),

2

to each page that contains protected material. If only a

3

portion or portions of the material on a page qualifies for

4

protection, the Producing Party also must clearly identify the

5

protected portion(s) (e.g., by making appropriate markings

6

in the margins).

7

b.

8

available for inspection need not designate them for

9

protection until after the inspecting Party has indicated

A Party or Non-Party that makes original documents

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

which documents it would like copied and produced. During

11

the inspection and before the designation, all of the material

12

made available for inspection shall be deemed

13

“CONFIDENTIAL.” After the inspecting Party has identified

14

the documents it wants copied and produced, the Producing

15

Party must determine which documents, or portions thereof,

16

qualify for protection under this Order. Then, before

17

producing the specified documents, the Producing Party

18

must affix the “CONFIDENTIAL legend” to each page that

19

contains Protected Material. If only a portion or portions of

20

the material on a page qualifies for protection, the Producing

21

Party also must clearly identify the protected portion(s) (e.g.,

22

by making appropriate markings in the margins).

23

c.

24

Designating Party identify the Disclosure or Discovery

25

Material on the record, before the close of the deposition all

26

protected testimony.

27

d.

28

document and for any other tangible items, that the

For testimony given in depositions, that the

For information produced in form other than

–7–
STIPULATED PROTECTIVE ORDER

1

Producing Party affix in a prominent place on the exterior of

2

the container or containers in which the information is

3

stored the legend “CONFIDENTIAL.” If only a portion or

4

portions of the information warrants protection, the

5

Producing Party, to the extent practicable, shall identify the

6

protected portion(s).

7

C.

Inadvertent Failure to Designate
1.

9

qualified information or items does not, standing alone, waive the

10
GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

8

Designating Party’s right to secure protection under this Order for

11

such material. Upon timely correction of a designation, the

12

Receiving Party must make reasonable efforts to assure that the

13

material is treated in accordance with the provisions of this Order.

14
15

If timely corrected, an inadvertent failure to designate

VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
A.

Timing of Challenges

16

1.

17

confidentiality at any time that is consistent with the Court’s

18

Scheduling Order.

19

B.

Any party or Non-Party may challenge a designation of

Meet and Confer

20

1.

The Challenging Party shall initiate the dispute resolution

21

process under Local Rule 37.1 et seq.

22

C.

The burden of persuasion in any such challenge proceeding shall

23

be on the Designating Party. Frivolous challenges, and those made for

24

an improper purpose (e.g., to harass or impose unnecessary expenses

25

and burdens on other parties) may expose the Challenging Party to

26

sanctions. Unless the Designating Party has waived or withdrawn the

27

confidentiality designation, all parties shall continue to afford the

28

material in question the level of protection to which it is entitled under
–8–
STIPULATED PROTECTIVE ORDER

1
2
3

the Producing Party’s designation until the Court rules on the challenge.
VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
A.

Basic Principles

4

1.

A Receiving Party may use Protected Material that is

5

disclosed or produced by another Party or by a Non-Party in

6

connection with this Action only for prosecuting, defending, or

7

attempting to settle this Action. Such Protected Material may be

8

disclosed only to the categories of persons and under the

9

conditions described in this Order. When the Action has been

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

terminated, a Receiving Party must comply with the provisions of

11

Section XIV below.

12

2.

13

Receiving Party at a location and in a secure manner that ensures

14

that access is limited to the persons authorized under this Order.

15

B.

Protected Material must be stored and maintained by a

Disclosure of “CONFIDENTIAL” Information or Items

16

1.

Unless otherwise ordered by the Court or permitted in

17

writing by the Designating Party, a Receiving Party may disclose

18

any information or item designated “CONFIDENTIAL” only to:

19

a.

The Receiving Party’s Outside Counsel of Record in

20

this Action, as well as employees of said Outside Counsel of

21

Record to whom it is reasonably necessary to disclose the

22

information for this Action;

23

b.

24

House Counsel) of the Receiving Party to whom disclosure is

25

reasonably necessary for this Action;

26

c.

27

Party to whom disclosure is reasonably necessary for this

28

Action and who have signed the “Acknowledgment and

The officers, directors, and employees (including

Experts (as defined in this Order) of the Receiving

–9–
STIPULATED PROTECTIVE ORDER

1

Agreement to Be Bound” (Exhibit A);

2

d.

The Court and its personnel;

3

e.

Court reporters and their staff;

4

f.

Professional jury or trial consultants, mock jurors, and

5

Professional Vendors to whom disclosure is reasonably

6

necessary or this Action and who have signed the

7

“Acknowledgment and Agreement to be Bound” attached as

8

Exhibit A hereto;

9

g.

The author or recipient of a document containing the

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

information or a custodian or other person who otherwise

11

possessed or knew the information;

12

h.

13

witnesses, in the Action to whom disclosure is reasonably

14

necessary provided: (i) the deposing party requests that the

15

witness sign the “Acknowledgment and Agreement to Be

16

Bound;” and (ii) they will not be permitted to keep any

17

confidential information unless they sign the

18

“Acknowledgment and Agreement to Be Bound,” unless

19

otherwise agreed by the Designating Party or ordered by the

20

Court. Pages of transcribed deposition testimony or exhibits

21

to depositions that reveal Protected Material may be

22

separately bound by the court reporter and may not be

23

disclosed to anyone except as permitted under this

24

Stipulated Protective Order; and

25

i.

26

supporting personnel, mutually agreed upon by any of the

27

parties engaged in settlement discussions.

During their depositions, witnesses, and attorneys for

Any mediator or settlement officer, and their

28
– 10 –
STIPULATED PROTECTIVE ORDER

1

IX. PROTECTED MATERIAL SUPOENAED OR ORDERED

2

PRODUCED

3

A.

4

litigation that compels disclosure of any information or items designated

5

in this Action as “CONFIDENTIAL,” that Party must:

IN OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other

6

1.

Promptly notify in writing the Designating Party. Such

7

notification shall include a copy of the subpoena or court order;

8

2.

9

subpoena or order to issue in the other litigation that some or all of

Promptly notify in writing the party who caused the

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

the material covered by the subpoena or order is subject to this

11

Protective Order. Such notification shall include a copy of this

12

Stipulated Protective Order; and

13

3.

14

to be pursued by the Designating Party whose Protected Material

15

may be affected.

Cooperate with respect to all reasonable procedures sought

16

B.

17

served with the subpoena or court order shall not produce any

18

information designated in this action as “CONFIDENTIAL” before a

19

determination by the Court from which the subpoena or order issued,

20

unless the Party has obtained the Designating Party’s permission. The

21

Designating Party shall bear the burden and expense of seeking

22

protection in that court of its confidential material and nothing in these

23

provisions should be construed as authorizing or encouraging a

24

Receiving Party in this Action to disobey a lawful directive from another

25

court.

26

X.

If the Designating Party timely seeks a protective order, the Party

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

27

PRODUCED IN THIS LITIGATION

28

A.

The terms of this Order are applicable to information produced by
– 11 –
STIPULATED PROTECTIVE ORDER

1

a Non-Party in this Action and designated as “CONFIDENTIAL.” Such

2

information produced by Non-Parties in connection with this litigation

3

is protected by the remedies and relief provided by this Order. Nothing

4

in these provisions should be construed as prohibiting a Non-Party from

5

seeking additional protections.

6

B.

7

to produce a Non-Party’s confidential information in its possession, and

8

the Party is subject to an agreement with the Non-Party not to produce

9

the Non-Party’s confidential information, then the Party shall:

In the event that a Party is required, by a valid discovery request,

Promptly notify in writing the Requesting Party and the

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

1.

11

Non-Party that some or all of the information requested is subject

12

to a confidentiality agreement with a Non-Party;

13

2.

14

Stipulated Protective Order in this Action, the relevant discovery

15

request(s), and a reasonably specific description of the information

16

requested; and

17

3.

18

the Non-Party, if requested.

Promptly provide the Non-Party with a copy of the

Make the information requested available for inspection by

If the Non-Party fails to seek a protective order from this court

19

C.

20

within 14 days of receiving the notice and accompanying information,

21

the Receiving Party may produce the Non-Party’s confidential

22

information responsive to the discovery request. If the Non-Party timely

23

seeks a protective order, the Receiving Party shall not produce any

24

information in its possession or control that is subject to the

25

confidentiality agreement with the Non-Party before a determination by

26

the court. Absent a court order to the contrary, the Non-Party shall bear

27

the burden and expense of seeking protection in this court of its

28

Protected Material.
– 12 –
STIPULATED PROTECTIVE ORDER

1

XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

2

A.

If a Receiving Party learns that, by inadvertence or otherwise, it

3

has disclosed Protected Material to any person or in any circumstance

4

not authorized under this Stipulated Protective Order, the Receiving

5

Party must immediately (1) notify in writing the Designating Party of the

6

unauthorized disclosures, (2) use its best efforts to retrieve all

7

unauthorized copies of the Protected Material, (3) inform the person or

8

persons to whom unauthorized disclosures were made of all the terms of

9

this Order, and (4) request such person or persons to execute the

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

“Acknowledgment and Agreement to be Bound” that is attached hereto

11

as Exhibit A.

12

XII. INADVERTENT PRODUCTION OF PRIVILEGED OR

13

OTHERWISE PROTECTED MATERIAL

14

A.

15

certain inadvertently produced material is subject to a claim of privilege

16

or other protection, the obligations of the Receiving Parties are those set

17

forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is

18

not intended to modify whatever procedure may be established in an e-

19

discovery order that provides for production without prior privilege

20

review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as

21

the parties reach an agreement on the effect of disclosure of a

22

communication or information covered by the attorney-client privilege

23

or work product protection, the parties may incorporate their agreement

24

in the Stipulated Protective Order submitted to the Court.

25
26

When a Producing Party gives notice to Receiving Parties that

XIII. MISCELLANEOUS
A.

Right to Further Relief

27

1.

28

seek its

Nothing in this Order abridges the right of any person to
modification by the Court in the future.
– 13 –
STIPULATED PROTECTIVE ORDER

1

B.

Right to Assert Other Objections
By stipulating to the entry of this Protective Order, no Party

2

1.

3

waives any right it otherwise would have to object to disclosing or

4

producing any information or item on any ground not addressed in

5

this Stipulated Protective Order. Similarly, no Party waives any

6

right to object on any ground to use in evidence of any of the

7

material covered by this Protective Order.

8

C.

Filing Protected Material
1.

9

A Party that seeks to file under seal any Protected Material

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

must comply with Civil Local Rule 79-5. Protected Material may

11

only be filed under seal pursuant to a court order authorizing the

12

sealing of the specific Protected Material at issue. If a Party's

13

request to file Protected Material under seal is denied by the Court,

14

then the Receiving Party may file the information in the public

15

record unless otherwise instructed by the Court.

16

XIV. FINAL DISPOSITION
After the final disposition of this Action, as defined in Section V,

17

A.

18

within sixty (60) days of a written request by the Designating Party, each

19

Receiving Party must return all Protected Material to the Producing

20

Party or destroy such material. As used in this subdivision, “all

21

Protected Material” includes all copies, abstracts, compilations,

22

summaries, and any other format reproducing or capturing any of the

23

Protected Material. Whether the Protected Material is returned or

24

destroyed, the Receiving Party must submit a written certification to the

25

Producing Party (and, if not the same person or entity, to the

26

Designating Party) by the 60 day deadline that (1) identifies (by

27

category, where appropriate) all the Protected Material that was

28

returned or destroyed and (2) affirms that the Receiving Party has not
– 14 –
STIPULATED PROTECTIVE ORDER

1

retained any copies, abstracts, compilations, summaries or any other

2

format reproducing or capturing any of the Protected Material.

3

Notwithstanding this provision, Counsel are entitled to retain an

4

archival copy of all pleadings, motion papers, trial, deposition, and

5

hearing transcripts, legal memoranda, correspondence, deposition and

6

trial exhibits, expert reports, attorney work product, and consultant and

7

expert work product, even if such materials contain Protected Material.

8

Any such archival copies that contain or constitute Protected Material

9

remain subject to this Protective Order as set forth in Section V.

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

B.

Any violation of this Order may be punished by any and all

11

appropriate measures including, without limitation, contempt

12

proceedings and/or monetary sanctions.

13
14

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

15
16

Dated:

April 27, 2021

/s/ Alejandro E. Figueroa
Alejandro E. Figueroa
Attorney for Plaintiff

Dated:

April 27, 2021

/s/ Brett B. Goodman
Brett B. Goodman
Attorney for Defendant

17
18
19
20
21
22
23
24

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25
26
27

Dated:

4/28/2021

/s/ CHARLES F. EICK
HONORABLE CHARLES F. EICK
United States Magistrate Judge

28
– 15 –
STIPULATED PROTECTIVE ORDER

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
I,

4

[print or type full name], of
[print or type full address], declare under penalty of perjury that I

5
6

have read in its entirety and understand the Stipulated Protective Order that

7

was issue by the United States District Court for the Central District of

8

California on __________ [DATE] in the case of Bryan Krough v. Southwest

9

Credit Systems, L.P., Case No. 2:20-cv-08535-JAK-E. I agree to comply with and

GOODMAN LAW FIRM, APC
11440 W. Bernardo Ct., Suite 300
San Diego, CA 92127

10

to be bound by all the terms of this Stipulated Protective Order and I

11

understand and acknowledge that failure to so comply could expose me to

12

sanctions and punishment in the nature of contempt. I solemnly promise that

13

I will not disclose in any manner any information or item that is subject to this

14

Stipulated Protective Order to any person or entity except in strict compliance

15

with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District

16
17

Court for the Central District of California for the purpose of enforcing the

18

terms of this Stipulated Protective Order, even if such enforcement

19

proceedings occur after termination of this action. I hereby appoint
[print or type full name] of

20

[print

21

or type full address and telephone number] as my California agent for service

22

of process in connection with this action or any proceedings related to

23

enforcement of this Stipulated Protective Order.

24

Date:

25

City and State where sworn and signed:

26

Printed Name:

27

Signature:

28
– 16 –
STIPULATED PROTECTIVE ORDER

1

SIGNATURE CERTIFICATION PURSUANT TO L.R. 5-4.3.4(2)(i)

2

I have obtained authorization from the above signatories to file the above-

3

referenced document, and the above signatories concur in the filing’s content.

4
5

GOODMAN LAW FIRM, APC

6

By: /s/ Brett B. Goodman
Brett B. Goodman
Attorneys for Defendant

7
8
9
10
GOODMAN LAW FIRM, APC
11440 w. Bernardo Ct., Suite 300
San Diego, CA. 92127

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

SIGNATURE CERTIFICATION

1

CERTIFICATE OF SERVICE

2

I certify that on April 28, 2021, a copy of the foregoing was filed and served

3

electronically in the ECF system. Notice of this filing will be sent to the parties of

4

record by operation of the Court’s electronic filing system. Parties may access this

5

filing through the Court’s system.

6
7
8
9
10
GOODMAN LAW FIRM, APC
11440 w. Bernardo Ct., Suite 300
San Diego, CA. 92127

11

DATED: April 28, 2021
GOODMAN LAW FIRM, APC
By:

/s/ Brett B. Goodman

Brett B. Goodman

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

CERTIFICATE OF SERVICE